This following document sets forth the Privacy Policy for the Grimsey Pty Ltd website, www.grimsey.com.au Grimsey Pty Ltd is committed to providing you with the best possible customer service experience. Grimsey Pty Ltd is bound by the Privacy Act 1988 (Crh), which sets out a number of principles concerning the privacy of individuals.

Collection of your personal information

There are many aspects of the site which can be viewed without providing personal information, however, for access to future Grimsey Pty Ltd customer support features you are required to submit personally identifiable information. This may include but not limited to a unique username and password, or provide sensitive information in the recovery of your lost password.

Use of your personal information

For each visitor to reach the site, we expressively collect the following non-personally identifiable information, including but not limited to browser type, version and language, operating system, pages viewed while browsing the Site, page access times and referring website address. This collected information is used solely internally for the purpose of gauging visitor traffic, trends and delivering personalized content to you while you are at this Site. From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our privacy notice. If our information practices change at some time in the future we will use for these new purposes only, data collected from the time of the policy change forward will adhere to our updated practices.

Changes to this Privacy Policy

Grimsey Pty Ltd reserves the right to make amendments to this Privacy Policy at any time. If you have objections to the Privacy Policy, you should not access or use the Site.

Accessing Your Personal Information

You have a right to access your personal information, subject to exceptions allowed by law. If you would like to do so, please let us know. You may be required to put your request in writing for security reasons. Grimsey Pty Ltd reserves the right to charge a fee for searching for, and providing access to, your information on a per request basis.

Contacting us

Grimsey Pty Ltd welcomes your comments regarding this Privacy Policy. If you have any questions about this Privacy Policy and would like further information, please contact us by any of the following means during business hours Monday to Friday. Post: Attn: Privacy Policy, Grimsey Pty Ltd, Level 2, 766 Elizabeth Street, Melbourne, Victoria, 3000 AUSTRALIA Telephone:(03) 9347 4400 E-mail: [email protected]

Privacy Policy for the Grimsey group of companies

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About this Document

This Privacy Policy covers the following businesses:Grimsey Financial Services Pty LtdGrimsey Pty Ltd Certified Practising AccountantsGrimsey Wealth (NSW) Pty Ltd

Commitment

Grimsey is committed to protecting the privacy and confidentiality of any personal or sensitive information that we may collect from you. This Privacy Policy outlines how we treat your information in accordance with the Australian Privacy Principles 2014 (APPs) established under the Privacy Amendment Act 1988 (Privacy Act). You can obtain further information regarding the APPs and your privacy rights at the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au. In this Privacy Policy, ‘Grimsey’, ‘we’, ‘us’, ‘our’ mean the entities carrying on business under the names of Grimsey Financial Services Pty Ltd, Grimsey Pty Ltd Certified Practising Accountants and Grimsey Wealth (NSW) Pty Ltd, and includes any corporate entity owned or controlled by these companies.

Personal or Sensitive Information we collect

To fulfill our ability to provide you with comprehensive financial planning, accounting and tax advice, we are dependent upon obtaining certain personal and/or sensitive information about you. This includes details such as:

  • Name, contact details and identification information such as tax file number
  • Family details including spouse and dependents
  • Employment information – current and history
  • Financial information – bank accounts, shareholdings, loans
  • Financial circumstances – assets and liabilities, income, expenditure, insurance, superannuation
  • Financial needs and goals
  • Risk and investment preferences
  • Insurance arrangements or sensitive information that might be required to obtain insurance cover

Purpose of Collecting Personal and Sensitive Information

Collection

We will primarily collect information from you directly including face-to-face meetings, over the telephone, by completing client questionnaires or when you send us some correspondence. On occasion it may be necessary to collect additional information from a third party like your personal representative or from publicly available records.

Purpose

Grimsey collect, hold and use your personal information so we can adequately provide the services you have requested, including:

  • Provide financial planning advice;
  • Prepare tax returns;
  • Prepare business activity statements;
  • Prepare financial accounts;
  • Provide recommendations on insurance and/or superannuation;
  • Provide recommendations and implementation on investment strategies;
  • Monitor your investment and share portfolios;
  • Review financial plans;
  • Provide recommendations on finance and loans; and
  • Liaise with third parties such banks, superannuation fund managers, life insurance companies and other financial institutions on your behalf.

Security

Your personal information is regarded as confidential and is held in both hard copy and electronic versions. Grimsey takes all possible precautions to ensure your information is not misused, lost, modified, accessed by unauthorised persons or disclosed. We have policies and procedures on the secure storage of your information and implemented technology security measures such as access passwords and firewalls on all devices.

Disclosure and Sharing of Personal and Sensitive Information

Disclosure

Grimsey will not disclose your personal or sensitive information for any purpose other than:

  • Provision of the services listed above;
  • Where you consent to such disclosure;
  • For a related purpose where you would reasonably expect such disclosure;
  • To provide you with direct marketing materials that may be of interest to you such as articles or product brochures; or
  • Any circumstance otherwise authorised by the Apps.

We may disclose your personal and sensitive information to the following entities:

  • Another Grimsey representative, relationship manager or contractor during periods when your relationship manager is away from the office, to ensure continued service. In circumstances where your relationship manager has referred you to another Grimsey relationship manager for the provision of other services;
  • The Australian Taxation Office (ATO) to meet ongoing compliance;
  • The Australian Securities & Investments Commission (ASIC) or Financial Planning Association (FPA) on request to meet ongoing compliance, mandatory professional standards and other legal obligations;
  • Insurance providers, superannuation fund managers and product issuers for the purpose of implementing your financial plan in accordance with the recommendations made by us;
  • Administrative service providers in regard to your investments to assist them with reporting, providing distributions and any other administrative tasks relating to your investments;
  • Our panel of approved SMSF auditors to arrange for the audit of your SMSF;
  • Approved entities who recommend and implement a direct share arrangement as part of your financial plan;
  • Persons who provide finance or other financial products to you or to whom an application has been made on your behalf;
  • As required by current law or directed by legal decision/process;
  • Financial consultants, lawyers, accountants and advisers; and
  • Any industry body, tribunal, court or otherwise connected with any complaint regarding our services.

Accessing, Updating and Correcting Your Personal and Sensitive Information

You can at any time request access to your personal information. Depending upon the complexity of the request, we will endeavour to respond within four weeks. In certain circumstances, the Apps provide that access can be denied but Grimsey will always give you a valid reason for doing so. Where the request requires significant time or is complex, we may charge reasonable costs for giving you such access. If at any time you believe that information we hold about you is incomplete, inaccurate, irrelevant, misleading or not up-to-date, please contact Grimsey with the evidence and we will take all steps necessary to correct in accordance with the Privacy Act.

Complaints

If you have a complaint regarding the way Grimsey have handled your information, you should contact us as per the details set out on page 1. We will endeavour to respond to your complaint promptly and in no less than 45 days. If you are not satisfied with our response to your complaint you can contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.